LivaNova - Ethics and Compliance

To help navigate the complex compliance environment in which we operate, LivaNova has adopted the AdvaMed Code of Ethics on Interactions with Health Care Professionals, the APACmed Code of Ethical Conduct, the Mecomed Code of Ethical Business Practice and the MedTech Europe Code of Ethical Business Practice.

These industry guidelines, along with the LivaNova Corporate Code of Conduct and LivaNova Corporate Compliance Policies, are the foundation of LivaNova's Compliance Program.
 

At LivaNova, we are committed to maintaining an effective and comprehensive compliance program. As a manufacturer of medical devices, LivaNova has designed our Corporate Compliance Program to comply with all applicable U.S. state and federal laws related to the promotion and sales of our products.
 
Our Corporate Compliance Program includes the following:

1. Code of conduct. Our Code of Ethics and Business Conduct is available in multiple languages.
2. Written policies and procedures. Our Corporate Compliance Policies and Procedures are made available to our employees via our Company intranet.
3. Assigned compliance officer. LivaNova has assigned a Compliance Officer who is responsible for implementing our Corporate Compliance Program.
4. Comprehensive training and education. LivaNova is committed to providing our employees with comprehensive compliance training and education on all of our Corporate Compliance policies and procedures.
5. Clear lines of communication for compliance reporting. LivaNova encourages a safe environment for all employees to Speak Up! and raise concerns.
6. Monitoring and auditing. LivaNova actively audits and monitors key processes to ensure compliance with the Company’s compliance policies and procedures.

To our knowledge, LivaNova is, in all material respects, in compliance with the California Health and Safety Code, Sections 119400-119402. Copies of this declaration, as well as additional details regarding our LivaNova Corporate Compliance Program, may be obtained by calling the LivaNova Ethics Line at +1 800-461-9330.
 
Last Updated: February 2020

At LivaNova, we believe it is the responsibility of all stakeholders to ensure we remain reputable leaders in compliance and business ethics. 

We encourage a safe environment for all individuals to speak up and raise any concerns they may have as it relates to the LivaNova Code of Ethics and Business Conduct, a related policy or any integrity issue.

LivaNova does not tolerate any form of retaliation against an individual arising from a good-faith report of a potential violation of our Code of Ethics and Business Conduct, a related policy, any integrity concern or against anyone who participates in an investigation resulting from a report.

You have several options on how to Speak Up:  

Phone

(800) 461-9330 (Additional local numbers are available here.)
The LivaNova Ethics Line is a toll-free telephone line managed by a third-party provider. If requested and allowable by local law, reporters will be granted full anonymity. The hotline is available globally and in multiple languages. 

Web

https://ethicshelpline.livanova.com
The LivaNova Ethics Line can also be reached via web through our third-party managed, confidential and anonymous (if requested and allowable by local law) online reporting tool.

Email

Ethics@LivaNova.com 
The LivaNova Ethics Inbox is managed by Corporate Compliance and any concerns received will remain confidential.

2019 Modern Slavery and Human Trafficking Statement

LivaNova PLC and its subsidiaries (individually or collectively, “LivaNova”), are committed to the highest ethical standards and compliance with laws and regulations applicable to our business, including laws related to slavery and human trafficking.

This statement sets out LivaNova’s commitment towards these efforts for the fiscal year ending 31 December 2019.

As part of our initiative to identify and mitigate risks, LivaNova has taken the following steps and is continuously working to further improve our policies and practices to ensure materials and services provided to LivaNova are procured only from suppliers who share this same level of commitment.

Policies and Internal Accountability

At LivaNova, we unite to provide hope for patients and their families through innovative medical technologies, delivering life-changing improvements for both the Head and Heart. This is our mission which we introduced in 2019.

We can only uphold this with the trust and respect of not only physicians and patients but of our employees, the communities in which we work, shareholders, partners, customers and suppliers.

That trust and respect comes with us meeting the highest standards of business ethics and compliance. It is not only what we do but how we do it. This includes laws related to slavery and human trafficking.

LivaNova supports the goals of the California Transparency in Supply Chains Act of 2010 and the United Kingdom Modern Slavery Act of 2015 and is committed to eradicating slavery and human trafficking from our business activities and supply chains.

In 2019, we began updating our Code of Ethics and Business Conduct to make it simpler, easier to read and give clear guidance on key expectations including human rights and modern slavery. The new code was launched in ten languages in early 2020 representing the key languages spoken across LivaNova.

To help employees make the best decisions, we also introduced a set of values as follows:

• Patients First. Our shared purpose is to improve the lives of patients
• Meaningful Innovation. We develop novel products and therapies to address multiple disease states
• Act with Agility. We challenge ourselves to continuously improve and act nimbly 
• Commitment to Quality and Integrity. We dedicate ourselves to high quality and integrity in everything we do
• Collaborative Culture. We value diversity of thought and our collective strength as a team

The Code of Ethics and Business Conduct is available, along with communication channels for reporting violations or concerns in good-faith in the hyperlinks provided.

Verification
LivaNova proactively promotes ethical behavior and encourages employees to report violation of laws, regulations, our Code of Ethics and Business Conduct and our policies and procedures. While we encourage employees to raise issues with their managers, we have also recently introduced a new and improved Ethics and Integrity Helpline where concerns can be reported confidentially and anonymously. All reports received are triaged to ensure timely and effective follow up. In 2019 we received no reports relating to human rights violations. In January 2020, we started a poster campaign at all sites stressing the importance of reporting issues and advertising the availability of the Ethics and Integrity Helpline.

In addition, prior to engaging with a third-party direct supplier, LivaNova evaluates direct suppliers through a risk-based business review process. Suppliers are expected to comply with applicable laws and regulations, including those related to slavery and human trafficking, as typically specified in our purchase order terms and conditions, contracts, or agreements.

Work has begun to upgrade our due diligence process to ensure we had appropriate risk assessment of third parties being engaged which includes looking at potential flags for human rights related risks. The pilot phase for the new process is ongoing and in 2020 we expect the process to be embedded in all new vendor selection and Procurement to Pay (P2P) processes.

Audit/Due Diligence
LivaNova reserves the right to verify supplier compliance with our defined requirements. We regularly audit suppliers who impact our quality system to confirm services or materials provided conform to defined requirements. Audits are performed by LivaNova or third parties contracted by LivaNova and may include site visits.

Certification
LivaNova reserves the right to request immediate corrective action where noncompliance is identified, and has the right to terminate agreements with those suppliers who do not comply with our terms and conditions.

While LivaNova requires compliance with all applicable laws in terms and conditions of purchase orders and agreements, we currently do not require our suppliers to certify material and services received comply with the laws specifically related to slavery and human trafficking.

Training

All LivaNova employees with regular computer access are required to commit to the new Code of Ethics and Business Conduct. Employees without regular computer access will be provided with copies of the new code.

The Code of Ethics and Business Conduct provides specific instructions on how employee’s can speak up and report potential violations or concerns. These speak up methods are also readily assessible via LivaNova’s intranet and company website and are also inlcuded on the Speak Up campagin posters which are on display in common areas throughout our facilities.

In addition, a monthly newsletter covering an assortment of ethics and integrity topics, including how to speak-up, human slavery, and other topics is sent to all employees having email access.

In 2020, the Code of Ethics and Business Conduct training will include short (2 minutes) videos of business leaders talking about key components of the code. One of these videos will focus on human rights and modern slavery.

Looking Ahead

Everything we do is intended to support our mission. LivaNova will continue to work to increase employee awareness of the risks around modern slavery, specifically those who are involved with sourcing and buying decisions. We will continue to work to improve our policies, programs, and procedures for how we identify and mitigate risks in our supply chains to ensure our suppliers and third party business partners are upholding the same level of commitment to compliance and business ethics as we do.

Damien McDonald
Chief Executive Officer and Director
LivaNova PLC

Archived Statements
2018 Modern Slavery and Human Trafficking Statement Archived
2017 Modern Slavery and Human Trafficking Statement Archived
2016 Modern Slavery and Human Trafficking Statement Archived 06-08-18

We strive to conduct our activities in a manner that reflects our mission and Code of Ethics and Business Conduct – which includes being a good corporate citizen, dealing fairly in business, behaving ethically, supporting a safe and healthy workplace, doing business in an environmentally responsible manner, and complying with applicable law. We are committed to ensuring that our supply chain reflects our values and beliefs, including adherence to principles of responsible sourcing for materials for our products. As part of our commitment, LivaNova supports the goals and objectives of Section 1502 of the Dodd Frank Act that requires public companies to determine the sourcing of conflict minerals used in their products. We expect our suppliers to support our efforts to comply with the Dodd Frank Act and to proactively identify and work towards eliminating the use of any minerals that fund or benefit armed groups from within our supply chain. In addition, we expect our suppliers to conduct business operations in an ethical manner and to comply with our Code of Conduct and all applicable laws related to environmental responsibility, workplace health and safety, and human resources.
 
View our Conflict Minerals Report.

Third Party Code of Ethics and Business Conduct

LivaNova is a worldwide leader in cardiovascular and neuromodulation solutions, dedicated to creating meaningful products and therapies that transform lives each and every day. We understand and respect the obligation we have to our patients and their families and caregivers as well as to our business partners and the environment at large.  We operate within a framework of principles, guidelines and policies aligned with ethical, social and environmental responsibilities, and we abide by the highest standards of business ethics and compliance, per our Code of Ethics and Business Conduct.
 
LivaNova embraces the key principles of the International Labour Organization’s fundamental conventions.  We believe that our business can only succeed where the rights of all workers involved in the value chain of our business are protected and respected, and we aim to conduct business with third parties including consultants, suppliers and other business partners (“Third Parties”) who share our commitment to operating in a responsible and ethical manner. Accordingly, this Third Party Code of Ethics and Business Conduct (“Code of Conduct”) outlines the minimum standards we require all LivaNova Third Parties to comply with when doing business with us, in addition to all applicable laws, regulations and industry standards.